DCT

2:26-cv-00851

Infogation Corp v. Attraction Technology Ltd

Key Events
Complaint
complaint Intelligence

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00851, E.D. Tex., 09/18/2026
  • Venue Allegations: Venue is alleged to be proper under the alien-venue rule, as the defendant is a foreign corporation organized under the laws of England and Wales.
  • Core Dispute: Plaintiff alleges that Defendant’s interactive wayfinding software and mobile applications infringe a patent related to navigation systems that use artistic, non-linearly scaled maps for display while performing route calculations on underlying, non-displayed geographic data.
  • Technical Context: The technology at issue involves digital mapping systems designed for venues such as theme parks and zoos, where a stylized, user-friendly map is displayed to the user, while traditional geographic coordinate data is used "behind the scenes" to calculate routes.
  • Key Procedural History: The complaint does not reference any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date Event
2007-08-11 ’628 Patent Priority Date
2018-10-23 ’628 Patent Issue Date
2026-09-18 Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,107,628 - Method and Apparatus for Navigating on Artistic Maps

  • Patent Identification: U.S. Patent No. 10,107,628 ("the ’628 Patent"), "Method and Apparatus for Navigating on Artistic Maps," issued on October 23, 2018. (Compl. ¶12).

The Invention Explained

  • Problem Addressed: The patent's background describes conventional GPS navigation systems as potentially "boring" and unhelpful in leisure settings like parks or zoos, as they may only display roads and fail to show nearby points of interest unless the user is very close. (’628 Patent, col. 1:40-54).
  • The Patented Solution: The invention proposes a navigation system that uses two distinct but linked maps: a user-facing "artistic map" and a non-displayed "geographical map" (’628 Patent, Fig. 3). The artistic map is "non-linearly scaled" and features "exaggeratedly shown" objects or points of interest to be more visually engaging and user-friendly (’628 Patent, col. 2:27-33). When a user selects a point on the artistic map, the system transforms the selection into geographic coordinates (e.g., latitude and longitude) on the hidden geographical map, calculates a route using this standard data, and then transforms the resulting navigational guidance back for display on the artistic map. (’628 Patent, col. 2:33-40).
  • Technical Importance: This approach enables the creation of intuitive and aesthetically pleasing navigation experiences for venues where strict geographic scale is less important than easily identifying and finding attractions. (’628 Patent, col. 1:60-65).

Key Claims at a Glance

  • The complaint asserts independent claims 1 (method) and 11 (apparatus), along with several dependent claims. (Compl. ¶28).
  • Independent Claim 1 (Method) includes the following essential elements:
    • Downloading an "artistic map" that is "non-linearly scaled" and has "exaggeratedly shown" objects.
    • Receiving a user's selection of one of the objects.
    • Determining coordinates for a point on the selected object.
    • Transforming these coordinates into a "physical point" (latitude and longitude) on a "geographical map" that is not displayed.
    • Detecting the device's current location.
    • Determining a navigational direction using the geographical map.
    • Showing the navigational direction on the displayed artistic map.
  • Independent Claim 11 (Apparatus) recites a portable device with a processor and memory configured to perform the core steps outlined in method claim 1. (’628 Patent, col. 9:30 - col. 10:11).
  • The complaint reserves the right to assert additional claims. (Compl. ¶26).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are identified as "MapLayr, Attractions.io interactive wayfinding, and customer-branded mobile applications implementing that technology." (Compl. ¶17). The complaint specifically mentions a "ZooTampa-branded application" and a "Six Flags" deployment as examples. (Compl. ¶6; Compl. ¶21).

Functionality and Market Context

  • The accused products are described as providing interactive wayfinding for venues by converting "geospatial data into custom, hand-illustrated map tiles" for display. (Compl. ¶19).
  • Functionality allegedly includes route plotting, GPS-enabled wayfinding, and estimated walking times. (Compl. ¶19; Compl. ¶20).
  • The complaint alleges that the accused systems maintain "georeferenced navigation and route data separately from the branded, stylized, or three-dimensional presentation layer shown to the user." (Compl. ¶24).
  • It is further alleged that the underlying geographic data is not displayed, and instead, route guidance is "transformed and rendered on the displayed artistic map." (Compl. ¶24).
  • The display is described as "non-linearly scaled" because objects like buildings and attractions are "enlarged, modeled, extruded, emphasized, or otherwise displayed out of strict geographic scale." (Compl. ¶25).

IV. Analysis of Infringement Allegations

The infringement theory posits that the accused MapLayr technology operates on the same two-layer principle as the patented invention: a stylized visual map for the user and a separate, non-displayed geographic data layer for calculation. The complaint includes a product image from the Defendant's website, showing a mobile device interface with a stylized map and route planning inputs overlaid with code snippets suggesting the import of a "MapLayr" module. (Compl. p. 4).

’628 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
downloading from a network into a computing device an artistic map, the artistic map being non-linearly scaled and including various objects being exaggeratedly shown... The accused system downloads map content and displays a "customized or artistic map" where objects are "enlarged... or otherwise displayed out of strict geographic scale." ¶22; ¶25 col. 8:26-30
receiving in the computing device a selection on the one of the objects from the user as a selected object The system permits "selection of a displayed object or destination," which are rendered as "selectable screen regions." ¶22; ¶23 col. 8:36-38
determining by the computing device a pair of coordinates for one of the points on the selected object "Selecting any point within the displayed region identifies substantially the same physical destination," which implies a coordinate determination from the selection. ¶23 col. 8:39-41
transforming in the computing device the pair of coordinates to a physical point represented by a pair of latitude and longitude in the geographical map not being shown on the display... The system uses "georeferenced navigation and route data separately from the... presentation layer," and this "geographic navigation data is not displayed directly." ¶24 col. 8:42-49
detecting a current location of the computing device in the geographical map The accused functionality includes "GPS-enabled wayfinding" and the ability to "determine current location." ¶20; ¶22 col. 8:50-51
determining according to the geographical map a navigational direction from the current location to the one of the objects being selected The system is alleged to "compute a route or direction using georeferenced navigation data." ¶22 col. 8:52-55
showing the navigational direction on the artistic map being displayed The system is alleged to "render that guidance on the displayed map" after it has been "transformed and rendered." ¶22; ¶24 col. 8:56-58

Identified Points of Contention

  • Technical Questions: A key factual question will be whether the accused system performs the claimed "transforming" step as required. The claim recites transforming coordinates from the artistic map to a physical point on the geographic map. The complaint alleges that route guidance is transformed and rendered on the artistic map. (Compl. ¶24). The litigation may focus on whether evidence shows that a user's tap on the displayed map is converted into a latitude/longitude coordinate for backend processing, as the claim requires.
  • Scope Questions: The dispute may center on whether the defendant's "custom, hand-illustrated map tiles" (Compl. ¶19) meet the definition of an "artistic map" as contemplated by the patent. Similarly, whether displaying objects "out of strict geographic scale" (Compl. ¶25) is sufficient to meet the "non-linearly scaled" limitation will be a likely point of contention.

V. Key Claim Terms for Construction

The Term: "artistic map"

  • Context and Importance: This term is foundational to the claims. Its construction will determine whether the accused "custom, hand-illustrated map tiles" and "stylized... presentation layer" fall within the patent's scope. (Compl. ¶19; Compl. ¶24). Practitioners may focus on this term because its breadth is central to the infringement case.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests the term can refer to any map that is "artisticly made to make the navigation as a pleasant experience" or shows "exaggeratedly points of interest." (’628 Patent, col. 1:63-65). This language may support an interpretation covering a wide range of stylized, non-standard maps.
    • Evidence for a Narrower Interpretation: The patent frequently provides examples in the context of leisure venues like a zoo. (’628 Patent, Fig. 1). This could be used to argue that "artistic map" is limited to illustrative, non-technical-looking maps typical of such venues, rather than any commercially stylized map.

The Term: "non-linearly scaled"

  • Context and Importance: This technical limitation is critical, as the plaintiff's infringement allegation relies on the accused maps being "displayed out of strict geographic scale." (Compl. ¶25). The definition of this term will be a focal point of claim construction.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent summary links "non-linearly scaled" to a map where "various objects being exaggeratedly shown." (’628 Patent, col. 2:44-45). This could support a broad definition that includes any map where the relative scale of objects is intentionally distorted for emphasis.
    • Evidence for a Narrower Interpretation: Figure 4C and its accompanying description disclose a specific form of non-linear scaling where the map's resolution is highest at the center and decreases toward the edges. (’628 Patent, col. 5:40-45; ’628 Patent, Fig. 4C). A party could argue this embodiment narrows the term to a specific "fisheye" type of scaling, rather than covering any and all disproportionate object sizing.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that the Defendant provides "documentation, SDKs, demonstrations, updates, marketing, and technical support instructing customers and users to operate the accused functions in the infringing manner." (Compl. ¶32). This is based on the theory that Defendant knowingly encourages its customers to directly infringe the ’628 Patent.
  • Willful Infringement: Willfulness is alleged based on knowledge of the ’628 Patent acquired "at least as of service of this Complaint." (Compl. ¶33). The complaint asserts that any continued infringement after receiving this notice is "deliberate and willful." (Compl. ¶34).

VII. Analyst’s Conclusion: Key Questions for the Case

  • Definitional Scope: A core issue will be one of claim construction: can the term "artistic map," which the patent illustrates with a zoo map example (’628 Patent, Fig. 1), be construed broadly enough to cover the accused "custom, hand-illustrated map tiles" and "stylized... presentation layer" used in commercial applications? (Compl. ¶19; Compl. ¶24).
  • Technical Proof: A key evidentiary question will be whether the plaintiff can demonstrate that the accused system performs the specific "transforming" step as claimed. The case may hinge on proof that a user's selection on the stylized map display is converted into a latitude/longitude coordinate pair for backend route calculation, as required by claim 1, rather than using an alternative method for linking displayed objects to navigation data.
  • Scope of "Non-Linearly Scaled": The outcome may depend on whether "non-linearly scaled" is interpreted broadly to mean any map with objects shown out of proportion for emphasis, as the complaint alleges (Compl. ¶25), or more narrowly to the specific center-focused scaling method disclosed as an embodiment in the patent's specification. (’628 Patent, Fig. 4C).